Vitract

Please read this document carefully.

Vitract, Inc. (“Vitract,” “we,” “us,” or “our”) respect your privacy. This Privacy Policy (“Policy”) describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our products or services to you (“Services”) and on the websites, applications, and online platforms that link to this Policy (collectively, “Site”), including when you apply for a job with us. It also describes rights you may have under applicable laws. Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it.

For further information on how we may collect, use, and disclose your health-related data, please review our Consumer Health Data Privacy Notice, which supplements this Policy.

Personal Information We Collect
We collect several categories of Personal Information from and about users of our Site and Services. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:

Contact Information – If you submit an inquiry, register for an account, or provide information on or through our Site or Services, we may collect your contact information including your name, mailing address, email address, social media handle, and phone number.
Commercial Information – If you submit an inquiry, or provide information on our Site, we may collect commercial information including information about your purchases, subscriptions, and Services you have shown interest in.
Usage Information – When you use our Site, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Site.
Communication Information – We may collect Personal Information contained within your communications with us via email, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and other communications with our agents, representatives, or employees via message, chat, post, or similar functionality. Additionally, if you enroll in Vitract University, we may collect any Personal Information you post to that community, whether you do so publicly or send via direct messaging.
Health Information – We may, with your consent, collect health-related information through the Platform as further explained in our Consumer Health Data Privacy Notice, which supplements this Policy.
Financial Information – If you make any purchases through our Services, we may collect financial information such as credit card details via our third-party payment processor(s), for example Stripe or other processors, to facilitate online payments. To understand how Stripe may use your Personal Information, please refer to Stripe’s Privacy Policy.

We may collect or generate “Deidentified Information,” that is, information that cannot reasonably be linked to you or your device. Deidentified Information is not Personal Information and is not subject to this Policy. However, we will maintain, use, and process your Deidentified Information only in deidentified form without attempting to reidentify it unless required to do so under applicable law or to assess our deidentification processes.

How We Collect Personal Information

Directly From You – We collect Personal Information that you provide to us directly, for example, if you choose to contact us, request information from us, sign up to receive updates, or otherwise utilize our Site or Services.
From Third Parties – We may collect Personal Information from third parties, including but not limited to business partners, advertising networks, social networks, data analytics providers, mobile device providers, Internet or mobile service providers, recruiters and job application portals, and background check providers.
Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information automatically as you navigate our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

How We Use Personal Information
To the extent permitted by applicable law, we use Personal Information:

To provide and personalize our Site and Services, such as processing or fulfilling orders and transactions, providing and personalizing our Services, processing payments, providing customer service, maintaining or servicing accounts, providing financing, verifying customer information, creating and maintaining business records, verifying eligibility, and undertaking or providing similar services.
To optimize, improve, and maintain our Services, including understanding how users interact with our Services, gauging user interest in certain Services or Site functionality, and troubleshooting problems.
For internal research and development, such as testing, verifying, and improving the quality of our Services or developing new ones.
For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. You can manage your marketing and other communications preferences by logging into your account on our Site. You can also unsubscribe from any marketing emails or text messages that we may send you by following the instructions included in the email or text correspondence or emailing us at [email protected].
For communicating with you, such as responding to your questions and comments or notifying you of changes to our Site or Services.
For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.

How We Disclose Personal Information
We may disclose aggregated information about our users, and Deidentified Information, without restriction.
We may disclose your Personal Information with your consent or in the following circumstances:

Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
Affiliates and Subsidiaries – We may share Personal Information within our family of companies for their and our business and marketing purposes, including providing you with information about the Services we think may be of interest to you.
Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
Business Partners – We may disclose Personal Information with trusted business partners. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
Other Users of Our Services – If you enroll in Vitract University, Personal Information you post to that community may be made available to other users, whether you do so publicly or send via direct messaging.
Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Vitract, its employees and clients, or the public against harm.
Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.

Website Delivery and Appearance – We may use third-party providers to enable certain customer interaction opportunities, content delivery (like audio or video), or other service capabilities. Examples include, but are not limited to, the following functionality:

Website Analytics and Session Replay – We use analytics and session replay services, that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, the following third-party services:

Google: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other third-party content, you should contact the responsible provider directly. It is in this context that we may provide data analytics providers, social networks, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.

Selling Personal Information – While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” under various data protection laws because it is sometimes broadly defined to include activities such as allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

Cookie Choices – To manage your preferences with respect to these technologies, you can change your cookie preferences by customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.

How Long We Keep Your Personal Information
We retain your information for as long as needed: (i) to conduct business with you; (ii) fulfill the purposes outlined in this Policy; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements. Criteria we will use to determine how long to retain your Personal Information include the nature and length of our business relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your Personal Information, such as communicating with you about ongoing or prospective Services you requested.

Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the terms and privacy policies for those platforms.

We may also integrate with other websites to provide enhanced services, technological capabilities, or resources for you. These plug-in services and capabilities are governed by the terms, conditions, and policies of the underlying companies. We may also give you the option to login to Vitract platforms via third-party services like Google. If you choose to leverage this option to link your accounts, we will receive information associated with your account (such as your name and profile information) from that third-party service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service. We recommend reviewing the service’s privacy policy beforehand and managing your privacy settings on an ongoing basis.

International Use and Cross-Border Data Transfers
If you are visiting our Site from outside of the United States, including Canada, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy. Note that the Site is intended for, and directed to, persons in the United States and Canada only. If you access the Site from outside of these countries, including from member states in the European Economic Area (“EEA”), your Personal Information may be processed outside of the protection of your local laws, including the EEA’s General Data Protection Regulation.

How We Protect Personal Information
We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

Exercising Your Privacy Rights
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
Opt Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted or cross-context behavioral advertising, (b) opt out of the sale of your Personal Information.
Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects.
Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

Even where not strictly required by applicable law, we will also process requests to limit the disclosure of your Personal Information to third parties. Note, however, that we may still be required to disclose your Personal Information to comply with applicable laws. Note also that, in some instances, your request to limit disclosure of your Personal Information may prevent us from providing you with certain products or services. Upon receipt of such a request, we will let you whether, and the extent to which, we will honor it.

To exercise any of the privacy rights afforded to you under applicable data protection laws or as otherwise explained above, please email us at [email protected].

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Policy. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

Children’s Privacy
We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law, without verified written parental consent, and we have no actual knowledge of selling such Personal Information of minors under 16 years of age. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information obtained from a child, please contact us at [email protected].

California Residents
California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at [email protected]. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

Changes to this Notice
Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Site. You are responsible for periodically visiting our Site and this Notice to check for any changes.

Contact Us
If you have any questions about our practices or this Notice, please contact us at [email protected].